I remember having to deal with that particularly poor definition of an
accelerator!! A shunt regulator tube in an old color TV set would
qualify as an accelerator by that definition! Along with SO many other
things that clearly aren't accelerators!
On 9/5/2012 2:33 PM, roseb at gdls.com wrote:
> John:
>> I am pleased to have wowed you!
>> I referenced the OLD DOE manual because I was not able to readily find the
> most recent manual online yesterday. After a bit more digging, I was able
> to locate the following:
>> DOE STANDARD: RADIOLOGICAL CONTROL (DOE-STD-1098-99), July 1999
>http://www.orau.org/ptp/PTP%20Library/library/DOE/Misc/Radiological_Control_Standard.pdf>> DOE O 420.2C, Safety of Accelerator Facilities (2011)
>https://www.directives.doe.gov/directives/0420.2-BOrder-c/view>> Article 365.3 in the 1999 DOE Radcon manual is the same as in the 1994 DOE
> Radcon manual, that article leaves the establishment of radiological
> controls for such devices to line management AND the Radiological Controls
> Organization (RCO) (DOE, p. 3-24, pdf p. 75/189). The policy also remains
> substantially the same.
>> The DOE order O 420.2C (2011) defines what constitutes and accelerator. An
> electron beam welder would fall under the definition of an accelerator.
> This order appears to still leave determination of the device exposure
> limits to management and the RCO.
>> FDA purview:
>> Compliance Guide for Cabinet X-Ray Systems
>http://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/GuidanceDocuments/ucm094358.htm>> The FDA does not appear in the above guide or 21CFR Subcahapter J to
> provide any specific or general guidance regarding leakage radiation
> limits for devices such as electron microscopes or electron beam welders.
>> Applicability of State regulations to the B&W Y-12 or other DOE site -
> State radiological health regulations, though possibly useful as a guide,
> might not be applicable at DOE sites or operations. Such sites are often
> considered federal enclaves or exclusive federal jurisdictions. Assuming
> the device is actually located in Tennessee at a DOE site or operation,
> and that the device is an electron beam welder, the following Tennessee
> rule could be applicable or used as guidance, since an electron beam
> welder appears to meet the definition of an accelerator in the rule
>> CHAPTER 0400-20-09, REQUIREMENTS FOR ACCELERATORS
>http://www.tn.gov/sos/rules/0400/0400-20/0400-20.htm>> The above rule does not provide any specific or general guidance regarding
> leakage radiation limits for an accelerator device. The guidance or
> requirements provided as to permissible radiation levels in the
> accelerator facility appear to be less stringent (2 mrem or 10 mrem, 0.02
> mSv or 0.10 mSv) in any one hour) than those in ANSI N43.3 for an Exempt
> Shielded Installation (0.5 mrem or 0.005 mSv in any one hour). The ANSI
> N43.3 radiation level criteria for an Exempt Shielded Installation appears
> to be a reasonable and feasible leakage radiation control limit for
> devices such as electron microscopes and electron beam welders, especially
> if the available data for these devices (i.e. manufacturer's data, site
> survey data, etc.) indicate reasonable entitlement for this control limit.
>> Henry
>> Boyd H. Rose, CM, CIH, CHMM, EI
> Sr. Safety and Environmental Engineering Specialist
> Corporate Radiation Safety Officer
> General Dynamics Land Systems
> 38500 Mound Road
> Mail Zone 436-10-75
> Sterling Heights , MI 48310-3269
> Tel: 586 825 4503
> Fax: 586 825 4015
> E-mail: roseb at gdls.com>>>>>>> "Dixon, John E. (CDC/ONDIEH/NCEH)" <gyf7 at cdc.gov>
> Sent by: radsafe-bounces at agni.phys.iit.edu> 09/05/2012 01:17 PM
> Please respond to
> "The International Radiation Protection \(Health Physics\) Mailing List"
> <radsafe at agni.phys.iit.edu>
>>> To
> "The International Radiation Protection (Health Physics) Mailing List"
> <radsafe at agni.phys.iit.edu>
> cc
>> Subject
> Re: [ RadSafe ] Incidental Radiation Generating Device Leakage Radiation
> Limits
>>>>>>> Wow! That's the first time in a long time I have seen a reference to the
> OLD DOE (Admiral Watkins) Radcon Manual! I am not certain if this topic is
> addressed in newer DOE regulations. The leakage levels in question may be
> addressed by certain TN State regulations (series 1200***), but these
> would be noted as radiation boundary levels, not allowable leakage. The
> ANSI standard N43.3 might be best used here (it is one of many developed
> for homeland security applications).
>> For these kinds of radiation generation devices, some NCRP's might be of
> use. In particular, NCRP 20 (for cargo scanning systems) might be
> applicable. I would also try NCRP-147 or 144. Look for the same key words:
> exempt, shielded, or as installed facility.
>> I would also research the purview of the Food and Drug Administration. If
> you go their home page and search for ionizing radiation devices
> manufactures standards, you might find this leakage limit as applicable
> prior to the device being purchased for such uses. Non-ionizing radiation
> generating devices, such as commercial microwave ovens, are included under
> the FDA's responsibilities.
>> Hope this helps.
>> Regards,
> John E. Dixon, CHP
>> -----Original Message-----
> From: radsafe-bounces at health.phys.iit.edu [
> mailto:radsafe-bounces at health.phys.iit.edu] On Behalf Of roseb at gdls.com> Sent: Tuesday, September 04, 2012 10:03 AM
> To: The International Radiation Protection (Health Physics) Mailing List
> Subject: Re: [ RadSafe ] Incidental Radiation Generating Device Leakage
> Radiation Limits
>> Randy:
>> Reference U.S. Department of Energy Radiological Control Manual,
> DOE/EH-0256T, Revision 1 (1994),
>https://www.orau.org/PTP/PTP%20Library/library/DOE/Misc/doe_rcm.pdf .
>> The DOE appears to have recognized the absence of specific federal
> radiological health standards for certain devices in their Radcon Manual
> (1994), and referred management and the RCO to applicable ANSI standards.
> As you are aware, in the case of devices such as electron microscopes and
> electron beam welders, Article 365.3 leaves the establishment of
> radiological controls for such devices to line management AND the
> Radiological Controls Organization (RCO) (DOE, p. 3-29, pdf p. 93/220).
>> Given the absence of a specific federal standard for the devices under
> consideration, and, given that the location where the devices are operated
> is likely a federal enclave or exclusive federal jurisdiction with respect
> to state radiological health regulations (state regs might not apply),
> your reference to the ANSI N43.3 Exempt Shielded Installation criteria
> dose equivalent limit of 0.005 mSv (0.5 mrem) in any one hour at any
> accessible area 5 cm (2 inches) from the outside surface of the enclosure
> (N43.3-2008, para. 5.1.10, p.9, pdf p. 18/79) appears to be a reasonable
> and feasible radiological control measure that is consistent with the DOE
> Radiological Health and Safety Policy (DOE, p. i, pdf p. 3/220).
>> Henry
>> Boyd H. Rose, CM, CIH, CHMM, EI
> Sr. Safety and Environmental Engineering Specialist Corporate Radiation
> Safety Officer General Dynamics Land Systems
> 38500 Mound Road
> Mail Zone 436-10-75
> Sterling Heights , MI 48310-3269
> Tel: 586 825 4503
> Fax: 586 825 4015
> E-mail: roseb at gdls.com>>>>>> "Redmond, Randy (RXQ)" <redmondrr at y12.doe.gov> Sent by:
>radsafe-bounces at agni.phys.iit.edu> 09/04/2012 07:25 AM
> Please respond to
> "The International Radiation Protection \(Health Physics\) Mailing List"
> <radsafe at agni.phys.iit.edu>
>>> To
> "radsafe at health.phys.iit.edu" <radsafe at agni.phys.iit.edu>
> cc
>> Subject
> [ RadSafe ] Incidental Radiation Generating Device Leakage Radiation
> Limits
>>>>>>> Does anyone know a citation for federal leakage radiation limits for
> incidental radiation generating devices such as electron beam welders and
> electron microscopes? I have searched and cannot find any. As a default,
> I'm using ANSI N43.3 Exempt Shielded Installation criteria of 0.5 mrem at
> 5 cm.
>> Thanks,
>> Randy Redmond
> B&W Y-12
> Radiological Engineering
> 865.574.5640
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